`Sent: Monday, September 20, 2021 10:15 PM
`To: Trials <Trials@USPTO.GOV>
`Cc: TD-PTAB <TD-PTAB@devlinlawfirm.com>; Google Jenam PGR <PH-Google-Jenam-
`PGR@paulhastings.com>; Derek Dahlgren <ddahlgren@devlinlawfirm.com>; Srikant Cheruvu
`<scheruvu@devlinlawfirm.com>; DLF-Lit Paras <dlflitparas@devlinlawfirm.com>
`Subject: PGR2021-00082
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`Dear Honorable Patent Trial and Appeal Board,
`
`Petitioner seeks authorization to file a 5-page reply to Patent Owner’s Preliminary Response in the
`above-identified PGR to address Patent Owner’s arguments regarding adverse judgment. See, e.g.,
`PGR2021-00082, POPR (Paper 6) at 5-6, 7-9. Petitioner would like to make sure the factual record and
`discussion of the caselaw regarding adverse judgment including Federal Circuit precedent is complete
`with respect to Patent Owner’s characterizations of the issues.
`
`Petitioner conferred with Patent Owner. Patent Owner opposes Petitioner’s request. Patent Owner’s
`position is that the record and law are clear and further briefing would be a waste of resources for all
`involved. Should the Board authorize Petitioner to file a reply, however, Patent Owner requests that the
`reply be limited to 2 pages and that Patent Owner be authorized to file a 2-page sur-reply.
`
`Petitioner does not oppose Patent Owner’s request for a sur-reply limited to issues raised in Petitioner’s
`reply.
`
`The parties can make themselves available for a conference call, should the Board find it helpful.
`
`Respectfully submitted,
`Naveen Modi
`Counsel for Petitioner Google
`
`
`Naveen Modi | Partner & Global Vice Chair of IP, Litigation
`Department
`Paul Hastings LLP | 2050 M Street NW, Washington, DC 20036 | Direct:
`+1.202.551.1990 | Main: +1.202.551.1700 | Fax: +1.202.551.0490 |
`naveenmodi@paulhastings.com | www.paulhastings.com
`
`
`
`
`
`
`
`******************************************************************************************
`This message is sent by a law firm and may contain information that is privileged or confidential. If you received
`this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments.
`If you reply to this message, Paul Hastings may collect personal information including your name, business name
`and other contact details, and IP address. For more information about Paul Hastings’ information collection, privacy
`and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com.
`
`
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